Millions of Americans preparing to select health insurance for 2027 will face changes to the Affordable Care Act (ACA) marketplace when open enrollment begins on November 1 in most states.
The upcoming enrollment period comes with stricter identity verification requirements, restrictions on which insurance agents can assist consumers, higher projected premiums and reduced financial assistance following the expiration of enhanced subsidies at the end of 2025.
The changes affect both the process of obtaining coverage and the amount many households will have to pay for insurance.
New Identity Checks Introduced to Prevent Fraudulent Enrolments
The Centers for Medicare & Medicaid Services (CMS) has introduced additional identity verification requirements for consumers enrolling through brokers or agents in the 29 states served by the federal marketplace.
The measures are intended to prevent fraudulent enrolments, including cases in which agents allegedly change customers’ insurance plans without authorisation to collect commissions.
Under the new process, consumers must confirm their authorisation for an agent through a one-time code sent by text message, email or telephone.
Additional checks apply to consumers classified as high-risk. These include first-time applicants, people moving between states, those changing agents and individuals whose monthly premiums are $30 or less.
Consumers in these categories must undergo identity verification through a third-party service such as Experian. If the automated process fails, they may be required to upload documents, including a driving licence, passport or immigration papers.
Experts Warn Verification Rules Could Discourage Some Applicants
Stacey Pogue, a senior research fellow at Georgetown University’s Center on Health Insurance Reforms, said efforts to prevent fraudulent enrolments were appropriate but warned that the additional requirements could create difficulties for legitimate applicants.
She said some consumers might fail verification because they lacked a credit file, had recently moved or had changed their names.
Joshua Brooker, an insurance agency owner in Pennsylvania, estimated that as many as one in five consumers could face the additional verification process.
He warned that some applicants might abandon their attempts to obtain coverage rather than complete the extra administrative steps.
New Broker Registration Rules Restrict Assistance During Enrollment
CMS has also introduced a moratorium preventing insurance agents who were not registered with the federal marketplace in 2026 from assisting with 2027 enrolments until February at the earliest.
Because the annual open enrollment period generally ends in January, the restriction effectively prevents many new or recently re-registered agents from helping customers select ACA plans for the coming year.
The administration said the measure followed compliance concerns involving newly registered agents and the removal of hundreds of brokers who failed to meet requirements during the year.
However, the restriction reduces the number of agents available to assist consumers during the enrollment period.
Jason Fine, who operates a brokerage in Florida, said the effort to reduce fraud could create significant disruption in the short term.
Smaller independent agencies that depend on seasonal workers have faced difficulties finding agents who meet the 2026 registration requirement. Larger call centres with permanent staffing may be better positioned to operate under the new rules.
Insurance Industry Groups Challenge the Broker Restrictions
Industry organisations have taken legal action against the moratorium, arguing that it unfairly limits the ability of agents to work during the enrollment period.
The National Association of Benefits and Insurance Professionals filed a lawsuit on October 15, challenging the restriction, which it says affects approximately 19,000 agents.
Ronnell Nolan, president of Health Agents for America, also filed a separate lawsuit seeking a temporary restraining order.
Nolan argued that being a newly registered agent did not automatically mean a person was involved in fraudulent activity.
Reduced Subsidies and Rising Premiums Increase Costs
The cost of coverage remains a major concern for consumers preparing to enrol for 2027.
Although many people will continue receiving financial assistance, the expiration of enhanced subsidies means support will be lower for eligible households than it was previously.
ACA subsidies are calculated using the premium of the second-lowest-cost silver plan available in a particular area. Changes in the cost of these benchmark plans affect the amount of assistance consumers receive.
Premiums for 2027 are projected to increase by an average of 15%, below the 26% average increase recorded in the previous cycle.
Insurers have attributed rising costs to concerns about changes in the insurance risk pool as healthier consumers drop coverage, as well as inflation, higher medical expenses and labour shortages.
Louise Norris, a health policy analyst for HealthInsurance.org, said affordability could remain broadly similar for some consumers who were already managing their current premiums.
However, people earning more than four times the federal poverty level will lose access to subsidies under the income limits described in the report.
The stated thresholds are $63,840 for an individual, $86,560 for a couple and $109,280 for a family of three.
Consumers Urged to Compare Plans Before Automatic Renewal
Consumers have been advised to review their insurance options rather than allow existing plans to renew automatically.
Premiums, coverage terms and the availability of insurers can change from year to year, making it important for customers to compare available policies before selecting coverage for 2027.
The comparison should include monthly premiums, deductibles and the maximum out-of-pocket limit, which determines how much a policyholder must pay for covered in-network care before the insurer covers the remaining eligible expenses.
The maximum out-of-pocket limit is set to rise by 13% in 2027, reaching $12,000 for individuals and $24,000 for families.
New Law Changes Which Immigrants Qualify for Subsidies
The One Big Beautiful Bill Act has also changed eligibility for ACA financial assistance, excluding many lawfully present immigrants from receiving subsidies.
The groups identified in the report include people with temporary H-1B work visas, refugees, asylees, individuals with temporary protected status and applicants with pending green-card applications.
The report identifies three categories that retain access to subsidies: green-card holders with permanent legal status, certain Cuban and Haitian immigrants, and citizens of Micronesia, the Marshall Islands or Palau.
For immigrants who lose eligibility, the removal of financial assistance means they may have to pay the full market price for health insurance.
The changes to eligibility, combined with higher projected premiums and stricter enrollment procedures, will shape the options available to Americans seeking ACA coverage for 2027.
